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GAO-09-392R:
United States Government Accountability Office:
Washington, DC 20548:
February 20, 2009:
The Honorable Eleanor Holmes Norton:
Chairwoman:
Subcommittee on Economic Development, Public Buildings, and Emergency
Management:
Committee on Transportation and Infrastructure:
House of Representatives:
Subject: Government Printing Office: Issues Faced in Obtaining a New
Facility:
Dear Madam Chairwoman:
The main facility for the Government Printing Office (GPO) is
inefficiently configured, aging, and much larger than needed. GPO has
examined several options for obtaining a new facility, including
leasing a new facility to be built on its current site while outleasing
(leasing as a landlord) its property to partially offset operational
costs. As requested, we reviewed (1) GPO's analysis of options to
obtain a new facility and the extent to which GPO has followed leading
practices for capital decision making and (2) issues, if any, that
impede GPO's efforts to obtain a new facility. This report summarizes
the results of our work that we provided to your staff during our
February 5, 2009 briefing. Our briefing slides can be found in
enclosure I.
Summary:
GPO partially followed leading practices for capital decision making
during analyses of options that it conducted in 2005 and 2008, but it
did not conduct cost-benefit analyses that explored a full range of
options for obtaining a new facility.
* While both of GPO's analyses considered innovative approaches for
obtaining a new facility, several options were overlooked, such as
reconfiguring the current facility. Comparing a wider range of options
would help decision makers determine the most cost-beneficial way to
obtain a new facility.
* In addition, although GPO identified some benefits of leasing a new
facility to be built on its current site, GPO did not conduct cost-
benefit analyses--systematic, quantitative assessments that take a
broad, long-term view of future effects.
* Furthermore, in estimating operations costs, neither of GPO's
analyses fully considers the effect of current labor and electricity
costs. Instead, the analyses rely on industry benchmarks to estimate
operations expenses. As a result, we believe that these analyses
overestimate the savings to be gained from leasing a new facility.
According to GPO officials, several issues impede GPO's efforts to
obtain a new facility.
* One key issue is GPO's lack of legislative authority to outlease
property and retain and use the proceeds from an outlease. GPO would
like to receive this legislative authority before it proceeds with
additional analyses on obtaining a new facility. If GPO is granted
legislative authority to retain and use the proceeds from an outlease
but that authority is not linked to a specific proposal for GPO to
acquire a new facility, decision makers may not have an opportunity to
evaluate the potential effects of GPO's long-term plans. Alternatively,
Congress could grant GPO outleasing authority only if it is needed to
implement the best option--identified through a cost-benefit analysis-
-for obtaining a new facility.
* Another issue GPO would face if it were to outlease a facility is its
lack of expertise in managing leases as a landlord. To its credit, GPO
has already solicited the real property management expertise of the
General Services Administration (GSA). GSA provides guidance to other
agencies--such as the Armed Forces Retirement Home (AFRH)--in managing
property and could guide GPO in complying with historic preservation,
environmental, and federal and local planning requirements.
To conduct our work, we analyzed GPO studies and interviewed officials
with AFRH, the Architect of the Capitol, GPO, the District of Columbia,
GSA, the Commission of Fine Arts, and the National Capital Planning
Commission, among others. GPO officials reviewed a draft of this
briefing and generally agreed with the findings, including the need to
conduct a cost-benefit analysis. However, they maintained that the
analysis should be done after legislative authority is granted. They
also provided technical corrections, which we incorporated as
appropriate. We conducted this performance audit from April 2008 to
December 2008 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained meets these standards.
We are sending copies of this report to interested congressional
committees and subcommittees with responsibilities for federal
facilities and to the Public Printer. The report will also be available
at no charge on GAO's Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-2834 or dornt@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report were Sara
Vermillion, Assistant Director; Amy Abramowitz; George Depaoli;
Elizabeth Eisenstadt; Carol Henn; Kieran McCarthy; Susan Michal-Smith;
and Ruth Walk.
Sincerely yours,
Signed by:
Terrell G. Dorn, P.E.
Director, Physical Infrastructure Issues:
Enclosure:
[End of letter]
Enclosure I: Government Printing Office Briefing:
Government Printing Office: Issues Faced In Obtaining A New Facility:
Why GAO Did This Study:
The Government Printing Office (GPO), within the legislative branch, is
the federal government’s primary resource for gathering, producing, and
preserving published federal information. GPO’s main facility —located
5 blocks from the U.S. Capitol—encompasses about 1.5 million square
feet and consists of four buildings that range in age from 68 to 105
years. According to GPO officials, the facility is inefficiently
configured, aging, and much larger than needed. As a result, GPO has
examined several options for obtaining a new facility. In 1982, GAO
recommended that GPO conduct a cost-benefit analysis of the various
options available to address the inefficiencies in its facilities.
GAO was asked to examine GPO’s efforts to obtain a new facility.
Accordingly, this briefing provides preliminary information on (1)
GPO’s analysis of options to obtain a new facility and the extent to
which GPO has followed leading practices for capital decision-making
and (2) issues, if any, that impede GPO’s efforts to obtain a new
facility. To conduct this work, GAO analyzed GPO studies and
interviewed GPO and District government officials, among others. GPO
officials reviewed a draft of this briefing and generally agreed with
the findings, including the need to conduct a cost-benefit analysis.
However, they maintained that the analysis should be done after
legislative authority is granted. They also provided technical
corrections, which we incorporated as appropriate.
Summary of Results:
GPO commissioned two analyses of options to obtain a new facility and
partially followed leading practices for capital decision-making, but
it did not conduct a cost-benefit analysis that explored a full range
of options. The first analysis (2005) explored three options to obtain
a new facility for GPO including leasing a new facility from the
private sector. All three options envisioned redeveloping GPO’s current
site to help pay for the agency’s relocation to a new site. The second
analysis (2008) involved a different approach—building a new facility
on the existing federally owned site, while still redeveloping the
current buildings to generate lease income. Leading practices for
capital decision-making could guide GPO’s next steps. Specifically, a
cost-benefit analysis of a full range of options would provide GPO and
Congress useful information for decisionmaking.
According to GPO, issues that impede its efforts to obtain a new
facility include 1) a lack of legislative authority to outlease (lease
as a landlord) and 2) potential difficulty in obtaining federal funds.
GPO lacks authority to outlease or sell its real property and retain
and use the proceeds from the lease or sale to help pay for its
operations. Also, CBO determined that to implement its 2005 proposal,
GPO would need to cover the full cost—not just the annual cost—of a new
facility in the first year, which could be difficult. If GPO were
granted legislative authority to retain and use the proceeds from an
outlease or a sale without a link to a proposal to acquire a new
facility, CBO and decisionmakers might not have the opportunity to
evaluate the full effects of GPO’s long-term plans. Alternatively, to
ensure that the costs of all options are appropriately compared,
Congress could make granting the authority to outlease and retain the
proceeds contingent on GPO conducting a cost-benefit analysis that
would examine a full range of options for a new facility.
Figure: Aerial View of the Current GPO Site and Buildings 1 through 4:
[Refer to PDF for image]
This figure is an aerial photograph of the current GPO site and
buildings 1 through 4. Also included is an outline of the proposed
construction site.
Source: US Geological Survey (aerial photograph); and GAO (graphics).
[End of figure]
Why GPO Says It Needs a New Headquarters Facility:
* The layout of the current buildings does not efficiently support
GPO’s current operations. GPO estimates that the buildings contain 3
times more space than it needs. (Current facility: 1.5 million square
feet; New facility requirements: 500,000 square feet.)
* The buildings’ multistory construction and additions over the years
impede efficiency in handling materials. GPO functions are
inefficiently located in four buildings and on multiple floors,
increasing operating costs.
* The buildings are expensive to operate because of their size, age,
and condition. They require extensive repairs that compete with more
forward-looking initiatives. According to GPO officials, the
replacement of GPO’s obsolete elevator system is but one of many
capital improvements GPO has deferred—risking critical failure—because
of budget constraints.
In addition, GPO officials note that the facilities are sited on some
of the most expensive land in the Washington metropolitan region, whose
sale or lease could be financially advantageous to the federal
government.
GPO Commissioned Two Analyses of Options for Obtaining a New Facility:
GPO commissioned two analyses, completed in 2005 and 2008, of some
options to develop a new facility for GPO. The 2005 analysis explored
three options to lease or sell GPO’s current property to acquire a new
facility through a private-sector developer. GPO could (1) lease a new
facility and land from the private sector, (2) exchange the property on
its current headquarters site for a new facility and possibly collect
rent if the value of the current site exceeded that of the new
facility, or (3) lease a new facility on federal property other than
GPO’s current site from a developer who, in exchange for payment or
services, would gain the rights to develop this federal property
through what is called an enhanced-use lease. All three options
envisioned redeveloping GPO’s current site to generate lease income to
help pay for the relocation. This 2005 analysis found that the option
of moving to a new leased building, combined with the private sector’s
redevelopment of the existing GPO site, could save U.S. taxpayers
millions of dollars annually. However, we believe that this analysis
overestimates the savings, because it uses industry standards to
estimate a new facility’s cost per square foot and these standards do
not reflect GPO’s current high costs for labor and electricity.
When reviewing proposed legislation based on this 2005 analysis, under
which GPO would lease a new facility in the Washington, D.C., area, the
Congressional Budget Office (CBO) determined that the full cost of the
lease should be scored, or recorded in the budget, as new budget
authority at the time of the lease, and that the cost of the lease
would exceed the cost of purchasing a comparable facility. The budget-
scoring rules are intended to ensure that capital leases, such as the
one GPO proposed in 2005, are put on the same budgetary footing as
direct purchases of assets. The scoring rules help decision makers face
the full costs of their decisions up front. GPO officials believe that
CBO’s scoring determination discouraged any further legislative action.
Going forward, Congress has an opportunity to decide whether the
authority for GPO to outlease real property as a landlord and retain or
use the proceeds from development should be linked to a proposal to
acquire a new facility.
The 2008 analysis involved a different approach—leasing a new facility
built on GPO’s current site, which the federal government owns. Under
this approach, a private developer would redevelop the existing 1.5
million-square-foot facility and construct a new, mixed-use building of
approximately 1.5 million square feet on the site, one-third of which
would include GPO’s new facility, which GPO would lease back from the
developer. This analysis assumes GPO would retain lease payments from
the developer for its use of GPO’s land and existing buildings and use
those proceeds to help pay for GPO’s operations. According to GPO’s
2008 analysis, the approach could save taxpayers millions annually
compared with the costs of operating the current facility. However, we
believe that the savings estimates of the 2008 analysis do not reflect,
for example, GPO’s current high costs for labor and electricity.
Leading Practices in Capital Decision-making:
These practices promote efficient resource allocation through well-
informed decision-making by the federal government.
(1) Identify and Evaluate a Wide Range of Options—This practice
recommends analyzing a wide range of options before choosing an option
for a capital asset. It also asks decision makers to consider whether
needs can be met in other ways or without incurring significant risk.
(2) Conduct Appropriate Analyses to Support Decision-making—Projects
that are expensive or are crucial to an organization’s strategy require
a full assessment of where the investment of capital can achieve the
greatest benefit. Analyses should examine which capital asset options
are most affordable and cost-beneficial. For example, a cost-benefit
analysis should compare the life-cycle costs of various alternatives
and be adjusted to consider risk.
(3) Consider Innovative Funding Approaches—In a constrained budget
environment, this practice enhances an agency’s flexibility to finance
the full costs of capital projects without compromising Congress’
ability to make decisions on full costs.
(4) Adhere to Sustainable Design Principles—Sustainable design seeks to
positively affect public health and the environment, reduce operating
costs, and help create a sustainable community. Leading practices for
sustainable design ask if sustainability has been considered in all
aspects of an asset’s life-cycle.
GPO Partially Followed Leading Practices in Capital Decision-making:
In the two analyses of options for obtaining a new facility that it
commissioned, GPO partially followed leading practices in capital
decision-making.[Footnote 1] These practices could provide useful
information to guide GPO’s next steps.
Table: GPO’s Progress in Implementing Leading Practices for Choosing a
New Facility:
Identify and Evaluate a Wide Range of Options:
Partially implemented;
Conduct Appropriate Analyses to Support Decision-making:
Partially implemented;
Consider Innovative Funding Approaches:
Partially implemented;
Adhere to Sustainable Design Principles:
Partially implemented.
[End of table]
(1) Identify and Evaluate a Wide Range of Options —GPO’s 2005 analysis
considered relocating the main GPO facility to another site. In
addition, its 2008 analysis considers the option of locating a new
facility on property GPO already owns, eliminating the cost of
acquiring new land, and recognizes the advantage of having the land
immediately available, thus eliminating the need to identify an
alternative location. However, GPO does not explore in either analysis
how these options compare with a range of other options, such as
reconfiguring the current facility to make operations more efficient,
to help decision makers determine whether GPO can meet its desire for a
new facility in other, perhaps more cost-effective ways. We define
reconfiguration as any revamping of the current facility through
redesign and/or expansion of the current facility by building an annex
behind it.
(2) Conduct Appropriate Analyses to Support Decision-making — Although
GPO did identify some benefits of building a new facility on its
current site, GPO’s 2005 and 2008 analyses of its options for a new GPO
facility did not include several key analyses, including a cost-benefit
analysis. In addition to the operations and maintenance savings that
the 2005 and 2008 analyses indicated GPO would gain from moving to a
new facility, GPO identified other benefits of keeping the facility on
its current site.
* GPO headquarters would stay close to Capitol Hill and GPO’s
congressional customers.
• GPO employees would continue to have ready access to public
transportation at nearby Union Station. Almost half of GPO employees
depend on public transportation.
However, GPO did not conduct several key analyses to determine where an
investment of capital could achieve the greatest benefit.
* GPO did not conduct a full cost-benefit analysis of the identified
options. A cost-benefit analysis is a systematic, quantitative way of
assessing the desirability of government projects when it is important
to take a long view of future effects and a broad view of possible side
effects.
* Although the 2005 analysis identified five risks, including rising
construction costs, associated with the options considered, it did not
include a full risk analysis, which would quantify these risks and show
how they might affect the relative costs and benefits of various
alternatives. For example, a full risk analysis might identify
uncertainties, such as potential savings from labor cost reductions,
and estimate how they might affect overall cost estimates.
* Both the 2005 and the 2008 analysis also did not include a full life-
cycle analysis of a range of competing alternatives to show which
alternative would be the most cost-effective over the life of the
asset.
* Furthermore, both analyses did not include a sensitivity analysis to
show the effects of uncertainties on GPO’s estimates. A sensitivity
analysis can identify the response of a program’s costs and benefits to
changes in one or more uncertain elements of the analysis. For example,
GPO could show how increases or decreases in assumed rental rates for
office and residential space or assumed inflation rates would affect
overall revenue estimates.
* The operations cost estimates in both analyses do not fully consider
the impact of current labor and electricity costs, relying instead on
industry benchmarks to estimate operations expenses for the new
facility. As a result, we believe that these analyses overestimate the
savings to be gained from moving to a new facility. For example, in its
2005 analysis, GPO assumed a large reduction in its labor costs for
operations, maintenance, and repairs based primarily on the two-thirds
reduction in facility size. However, GPO proposed no corresponding
reduction in staff.
(3) Consider Innovative Funding Approaches—The 2005 and 2008 analyses
both explore alternatives to full up-front funding that would generate
funds from development to help pay for a new facility over a time frame
to be negotiated between GPO and the developer. GPO is considering a
funding approach that is similar to that undertaken by the Armed Forces
Retirement Home (AFRH),[Footnote 2] which is developing part of its
property to generate income to help pay for its rising expenses and
stagnant revenue stream after it received the authority to do so from
Congress in December 2001. Using federal land for private development
to fund an agency’s needs is a relatively new approach.
(4) Adherence to Sustainable Design Principles—While GPO considered
elements of sustainable design in its 2005 analyses, such as creating a
green roof on the main plant and using sustainable design to enhance
energy efficiency, GPO has not comprehensively considered how
sustainable design principles could be incorporated in a new facility
throughout its entire life cycle or whether various options are more
sustainable than others. For example, GPO has not fully evaluated
whether reconfiguring its current building is more or less sustainable
than constructing a new building.
Other Issues Facing GPO:
GPO will face additional issues if it proceeds with its current plan to
develop a new headquarters facility. For example, GPO will have to
address its lack of expertise with lease management as a landlord. To
its credit, GPO has already solicited the real property management
expertise of the General Services Administration (GSA). Just as it is
guiding AFRH in the development of its property, GSA could guide GPO in
complying with historic preservation, environmental, and federal and
local planning requirements when GPO moves to implement whatever
alternative it identifies as best for a new facility.
By involving stakeholders such as the Architect of the Capitol (AOC),
the District, and GSA, early, GPO could avoid issues down the road. In
addition, by continuing to involve these stakeholders throughout the
process, GPO could facilitate completion of a memorandum of
understanding on how the current site is to be developed, if
development of the current site is deemed the best alternative. GPO’s
2005 analysis includes a communication plan that outlines a
comprehensive strategy for engaging all stakeholders in whatever
alternative is selected.
GPO will also have to address the space needs of its current federal
tenants. For example, AOC currently leases storage and office space in
GPO’s current building for the Capitol Police and the Superintendent of
the Senate.
Issues That Impede GPO’s Efforts Include a Lack of Legislative
Authority to Outlease Property and Potential Difficulty in Obtaining
Federal Funds:
According to GPO, there are several issues that impede its efforts to
obtain a new facility. First, to implement the options identified in
its 2005 or 2008 analysis, GPO would need legislative authority to
outlease its property as a landlord and retain and use the proceeds
from such a lease to help defray operational costs.[Footnote 3] It
would also like the authority to sell its property and use the
proceeds, although it does not need this authority to implement the
options identified in the 2008 analysis. GPO would like to receive
these legislative authorities before it proceeds with additional
expenditures for analyses to further justify the best option for a new
facility—thereby eliminating uncertainty about whether the authority
will be available if the selected option requires such authority. If
GPO is granted legislative authority to retain and use the proceeds
from an outlease or sale without a link to a proposal to acquire a new
facility, CBO and decisionmakers may not have an opportunity to
evaluate the full effects of GPO’s long-term plans. As an alternative
to granting this legislative authority to GPO without tying it to a
specific proposal, Congress could grant GPO outleasing authority only
if it is needed to implement the option that a cost-benefit analysis of
a full range of options identifies as best.
Second, GPO faces potential difficulty in obtaining funds to pay for a
new facility. Agencies sometimes have difficulty obtaining funds for
projects that require a large increase in budget authority. GPO’s 2005
draft legislation, which would have authorized GPO to lease a new
facility in the Washington, D.C., area and to enter into agreements
with private-sector developers to share anticipated leasing proceeds
from the new development on GPO’s current site, was determined by CBO
to include a capital lease and thus not proposed to Congress. Budget
scoring rules require that the full cost of entering into a capital
lease for a new facility be applied in that fiscal year’s budget when
the budget authority first becomes available for expenditure. Making
the costs of decisions readily apparent in the budget before funds are
appropriated provides the transparency needed for effective
congressional and public oversight.
Third, uncertainties about the local real estate market—including the
market demand for office or residential space on the current GPO site,
the developer’s costs for loans to fund capital expenditures, and
construction costs—raise questions about whether GPO could obtain
sufficient revenues from redeveloping its property to make an option
that involves building an additional facility on the current site the
most cost-effective option for the federal government.
[End of enclosure]
Agency Comments and Our Evaluation:
GPO reviewed a draft of this briefing and generally agreed with the
findings, including the need to conduct a complete cost-benefit
analysis. However, GPO maintained that a detailed cost-benefit analysis
should only be carried out after it has obtained the legislative
authorities necessary to implement some of the options currently under
consideration, and after the Joint Committee on Printing (JCP) has
reviewed and approved the analysis. GPO offered two primary reasons for
this position.
(1) Because a cost-benefit analysis involves a significant investment
of time and money, this investment is potentially wasted if GPO does
not obtain the legislation it desires to proceed with the alternative
determined to be best.
(2) GPO would not have the detailed data to conduct a cost-benefit
analysis without knowing the terms and conditions of a transaction
between GPO and a developer.
We agree that if GPO conducts a cost-benefit analysis before receiving
the legislative authorities to implement some of the proposed options,
it risks losing a significant investment of time and money should it
not receive these authorities. However given the costs, risks, and
potentially different ways to meet GPO’s desire for a new facility, we
believe GPO should conduct this analysis to provide Congress with
sufficient information to make an informed decision about how to
proceed. We do not believe that detailed knowledge of a proposed
development transaction is required to conduct a complete cost-benefit
analysis. The level of detail included in GPO’s 2005 analysis is
sufficient in our view. However, we continue to believe that GPO must
conduct a cost-benefit analysis that examines a full range of
alternatives and uses actual costs instead of industry standards to
estimate any savings that may exist.
GPO also noted that requiring it to obtain JCP’s approval before
entering into any specific transaction should address our concern that
the full effect of GPO’s long-term plans might not be evaluated. We
agree that review and approval from JCP would be beneficial,
particularly if GPO had received prior legislative authority, as there
would be no other review process. However, we maintain that even if
this requirement for JCP’s approval is in place, without a complete
cost-benefit analysis that looks at a range of alternatives, JCP—and
Congress as a whole—may not be aware of the costs, benefits, and risks
of a range of alternatives and thus may not have the information to
make a fully informed decision.
[End of section]
Footnotes:
[1] We used both GAO’s Executive Guide: Leading Practices in Capital
Decision-making (GAO/AIMD-99-32) and the Office of Management and
Budget’s Capital Programming Guide as sources of leading practices for
choosing a capital asset to evaluate GPO’s efforts to identify the best
option for a new facility. These leading practices complement each
other.
[2] AFRH is an independent establishment in the executive branch of the
federal government.
[3] GPO currently has the authority to lease space as a tenant. See 44
U.S.C. § 309.
[End of section]
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